United States v. Lyons
731 F.2d 243 (1984)
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Rule of Law:
A person is not responsible for criminal conduct on the grounds of insanity unless, at the time of the conduct, as a result of a mental disease or defect, they were unable to appreciate the wrongfulness of that conduct. The volitional prong of the insanity defense, which excused a defendant who lacked substantial capacity to conform their conduct to the law, is abolished.
Facts:
- In 1978, Robert Lyons began suffering from several painful physical ailments.
- As part of his medical treatment, various doctors prescribed him narcotic drugs to be taken as needed for his pain.
- As a result of this prescribed medical treatment, Lyons developed an iatrogenic (medically-induced) addiction to the narcotics.
- Lyons was subsequently discovered to be securing controlled narcotics by means of misrepresentation, fraud, deception, and subterfuge.
- Lyons proffered evidence that his extreme addiction led to severe malnutrition, decalcified bones, and convulsions so powerful that he broke three ribs, three vertebrae, and dislocated his hip.
- Lyons also offered expert testimony that his drug addiction had caused both physiological and psychological damage to his brain.
Procedural Posture:
- Robert Lyons was indicted in a federal district court on twelve counts of fraudulently securing controlled narcotics.
- Before trial, Lyons notified the prosecution of his intent to rely on an insanity defense based on his medically-induced drug addiction.
- The government filed a motion in limine to prevent Lyons from presenting any evidence of his drug addiction to the jury.
- The district court granted the government's motion, excluding the evidence, which resulted in Lyons's conviction.
- Lyons appealed his conviction to the United States Court of Appeals for the Fifth Circuit.
- A three-judge panel of the court of appeals reversed the district court's decision.
- The United States Court of Appeals for the Fifth Circuit then voted to rehear the case en banc.
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Issue:
Does the volitional prong of the insanity defense, which absolves a defendant who lacks substantial capacity to conform his conduct to the requirements of the law, remain a valid standard for determining criminal responsibility?
Opinions:
Majority - Gee, Circuit Judge
No. A person is not responsible for criminal conduct on the grounds of insanity unless, at the time of that conduct, as a result of a mental disease or defect, they are unable to appreciate the wrongfulness of that conduct. The court abandons the volitional prong of the insanity defense—the inability to conform one's conduct to the law—because current psychiatric knowledge does not provide a sufficient scientific basis to distinguish between an irresistible impulse and an impulse that was merely not resisted. The volitional test invites fabrication, creates jury confusion, and imposes an all but impossible burden of proof on the prosecution. While mere drug addiction is not a mental disease or defect for legal purposes, evidence of addiction that causes actual physical brain damage or a drug-induced psychosis may be presented to show the defendant was unable to appreciate the wrongfulness of their conduct under the remaining cognitive prong of the defense. Because Lyons proffered such evidence, his conviction is vacated and remanded for a new trial under this new, more restrictive standard.
Dissenting - Johnson, Circuit Judge
The majority mischaracterizes the issue and Lyons's proffered evidence. The issue was not whether to redefine the insanity defense, but simply whether Lyons presented enough evidence under existing circuit precedent to have his defense heard by a jury. Lyons's proffer went far beyond 'mere addiction' and included evidence of severe physiological damage and expert testimony of brain damage. This was sufficient under the slight evidence standard of this Circuit to submit the issue to the jury. It is particularly inappropriate for the court to make such a drastic change to the insanity defense when Congress is actively considering legislative action on this very issue.
Concurring-in-part-and-dissenting-in-part - Rubin and Williams, Circuit Judges
We concur that iatrogenic narcotics addiction alone is insufficient to constitute a mental disease or defect for an insanity defense, which resolves this case. However, we dissent from the majority's decision to use this case as a vehicle to redefine the entire insanity defense, an issue not raised by either party on appeal. This is a 'serious misadventure in the judicial process' that demonstrates a lack of appropriate judicial self-restraint. The court should not be rewriting fundamental legal policy sua sponte, especially when the issue is the subject of intense national debate and potential Congressional action.
Analysis:
This decision represents a significant narrowing of the insanity defense in the Fifth Circuit, predating the federal Insanity Defense Reform Act of 1984 which would later codify a similar change nationwide. By abolishing the volitional prong, the court eliminated the 'irresistible impulse' defense, reflecting a growing skepticism in both legal and psychiatric fields about the ability to scientifically measure a person's capacity for self-control. This ruling shifted the insanity inquiry to a purely cognitive test, making the defense substantially more difficult to prove and aligning the circuit with a more conservative approach to criminal responsibility that emerged after the acquittal of John Hinckley Jr.
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